Q. I have a COBRA participant who is nearing the end of his 36-month maximum coverage period. What notices must I send him regarding coverage termination? — Cathleen, New Hampshire
A. It is important to let COBRA participants know when their coverage entitlement is coming to an end. Such a notice should explain the reason coverage has terminated, provide the date of termination and describe any rights the qualified beneficiary may have to elect alternative group or individual coverage, such as a conversion right (29 C.F.R. 2590.606-4(d)). The time for providing this notice is as soon as reasonably practicable following the plan administrator’s determination that continuation coverage will terminate (69 Fed. Reg. 30090).
This person may also be entitled to receive other notices under HIPAA, such as a notice of creditable coverage (so pre-existing conditions may be covered by any new plan). Work with your plan administrator to ensure required notices are made. Learn more about COBRA at the Department of Labor's website.